type: timeline_event
The Supreme Court issued three unanimous decisions addressing federal civil procedure and criminal sentencing. In Berk v. Choy (No. 24-440), Justice Barrett's 9-0 opinion held that Delaware's affidavit of merit requirement for medical malpractice cases does not apply in federal court, finding the state law conflicts with Federal Rules of Civil Procedure 8 and 12, which do not require plaintiffs to provide evidence at the pleadings stage.
In Coney Island Auto Parts v. Burton (No. 24-808), Justice Alito authored a 9-0 decision holding that Federal Rule of Civil Procedure 60(c)(1)'s "reasonable time" requirement applies to all Rule 60(b) motions, including those alleging void judgments under Rule 60(b)(4). The Court rejected arguments that parties could challenge void judgments at any time, establishing temporal limits on procedural challenges to default judgments.
In Ellingburg v. United States (No. 24-482), the Court held that restitution orders under the Mandatory Victims Restitution Act of 1996 (MVRA) constitute criminal punishment for Ex Post Facto Clause purposes. Petitioner Ellingburg committed his offense before MVRA's enactment but was sentenced under it and ordered to pay $7,567.25 in restitution, raising constitutional challenges to retroactive application of criminal penalties.
The unanimous decisions reflect technical consensus on procedural matters even as the Court remains deeply divided on substantive constitutional issues involving executive power, civil rights, and administrative law. The rulings clarify federal procedure standards affecting civil litigation and criminal sentencing nationwide.